Air Quality

Benzene Waste Operations NESHAPs (BWON)

The Benzene Waste Operations NESHAPs (BWON) was promulgated under 40 CFR Part 61, Subpart FF. Click here to download the rule. The BWON was unique in that it blended ideals of waste and water quality management into an air rule that was designed to reduce benzene emissions from facility waste. The rule has had a storied past including a stay of effectiveness on the initial rule that lasted until promulgation of the January 7, 1993 amendments which removed the stay and finalized the rule. The stay of effectiveness was established largely due to the widespread confusion regarding interpretation of the rule. The amendments were designed to clarify provisions of the initial rule that had been widely misunderstood. Even today, over a decade after initial promulgation and following multiple attempts to clarify aspects of the rule, regulated facilities continue to question how to apply the rule.

After years of focus and growth in the BWON field, Sage's expertise and experience is highly recognized and respected by both the industry and government regulators. Encompassing a wide variety of services in the area, Sage has assisted more than 50 refining facilities with their BWON processes – that's nearly one-third of the refining capacity in the United States. Sage's BWON offerings include the following:

Essential Services

If there is a BWON service offering you can imagine, we have likely done the work multiple times and our experience can be trusted. Further, our in-depth refining and petrochemical process knowledge provides us with insight beyond the regulation that is unsurpassed.

  • Annual and Quarterly Reporting
  • TAB and Uncontrolled Benzene Quantity Development and Assessment
  • Controls Evaluation
  • Compliance Auditing
  • Waste Management Unit Identification
  • Waste Management Unit Inspection and Monitoring
  • Day-to-Day Compliance Support
  • Sampling Services

Enhancement Services

The BWON rule has been one of the most contentious and enforced regulations for the past two decades. We have experience managing challenges associated with BWON, and know how to mitigate BWON risk and facilitate sustainable BWON compliance.


Articles and Presentations

Technical Guidance Documents


Sage has not only assisted with implementation of many consent decrees, but has supported facilities that have had recurring problems with their End of Line (EOL) estimates and solved those problems. We are well versed in all aspects of BWON compliance requirements, including compliance with Consent Decree BWON Enhancements as part of the Refinery and Chemical Enforcement Initiatives. Our services include:

Sage Serves You

Training is necessary to ensure that your staff has the proper knowledge, skills and abilities to manage a BWON program and is a requirement of many Consent Decrees. Sustaining an effective BWON compliance program is challenging without the right tools. Sage has pioneered a comprehensive BWON training program for all levels of your organization. Training includes:

  • BWON Introductory Training
  • Sample Technician Training/Certification
  • Operator Training
  • Executive /Manager Level Training
  • BWON Expert Training

For more information about BWON training, visit our site Illuminate Your Brain.

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